Q2 2025 Global Regulatory Recap: Key Compliance Updates for North America, EMEA, and APAC

The 3E Q2 regulatory update spans a number of disparate topics, with upcoming deadlines that companies should be aware of. This article summarizes content presented in 3E's Q2'25 Regulatory Roundup Webinar. Many topics are discussed, however, not every issue is summarized below. Companies should also listen to the webinar for a comprehensive overview of the upcoming changes.

North America: Key Regulatory Changes in Q2 2025

The overarching focus for the United States (U.S.) revolves around EPR – which is a regulatory strategy that places the responsibility for impacts of post-consumer products on the producers themselves instead of on municipalities. EPR came out of the EU Green Deal.

Obligations can include:

• Recycling and collection
• Reporting and labeling
• Eco-modulated fee structure.

Industries affected include: packaging, electronics, batteries, and textiles. However, EPR related to packaging is gaining the most momentum at this time.

At the time of this publication, more than half ofU.S. states have EPR regulations, however, only seven states have EPR packaging regulations.

States with EPR regulations are: Washington, Oregon, California, Montana, Utah, Colorado, Oklahoma, Texas, Louisiana, Arkansas, Missouri, Iowa, Minnestoa, Wisconsin, Florida, South Carolina, North Carolina, Virginia, West Virginia, Maryland, New Jersey, Pennsylvania, New York, Connecticut, Rhode Island, Massachusetts, Vermont, New Hampshire, and Maine.

States with EPR packaging regulations include: Washington, Oregon, California, Colorado, Minnesota, Maryland, and Maine. Notably, companies should be on the lookout for the four states that introduced or reintroduced EPR packaging bills: New York, New Jersey, Illinois, and Tennessee.

What companies should know:

Companies operating in Oregon should be aware that:

• The EPR system launched the first of this month (July 1, 2025)
• Producers of packaging, paper, and food serviceware must register with a PRO (among other responsibilities)
• Only items with end-market recyclability may display symbols indicating they are recyclable

Companies selling, distributing, or importing plastic packaging and single-use food serviceware into California, for use in California, are subject to data reporting for year 2023. The reporting due date is August 31, 2025.

Companies operating in Colorado that sell materials for residential or public space need to submit 2024 packaging data by July 31, 2025.

Companies selling or distributing packaging materials in Minnesota should be aware that a wide range of packaging products are included in the EPR legislation.

Companies in Maryland and Washington should be aware that Maryland passed a new bill on May 13, 2025 that includes a phased implementation with an anticipated rule-making in the year 2026. Washington passed a bill on May 17, 2025 that includes detailed accountability criteria.

In Maine, companies should expect final rules implementing EPR legislation to arise shortly.

Key Takeaways for Businesses

TEPR requirements are coming up fast in the U.S. and companies should continue tracking which states are implementing new requirements and which short-term deadlines need to be met.

How 3E can help

There are numerous ways to handle the challenges of EPR uncertainty. The first is to utilize horizon scanning techniques and to keep up with news and changes in the Federal Register. Once the updates are filtered out and only what is relevant is identified, companies still have to incorporate new requirements into workplace operations, product design workflows, and go-to-market strategies.

3E has a portfolio of products that help industries in many sectors identify regulatory changes and mitigate risks of noncompliance.

See 3E Insight for more information.

EMEA: Compliance Updates and Trends

In Q2, the European Union (EU) Commission published an action plan for the chemicals industry. The action plan has four key pillars that help guide EU policy:

• Resilience
• Affordable energy and decarbonization
• Lead markets and innovation
• Per- and polyfluoroalkyl substances (PFAS) Initiative

In addition, the EU released the sixth omnibus simplification package for chemicals, which includes:

• CLP Regulation (EC) No 1272/2008 (simplifies hazardous chemical labeling)
• Cosmetic Regulation (EC) No 1223/2009 (note Article 16, the prenotification obligation)
• Fertilizing Product Regulation (EU) 2019/1009 (note the removal of extended registration and the application of the standard Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) requirements)
• A new European Chemicals Agency (ECHA) Based Regulation (designed to improve efficiency)

Other developments that companies operating in the EU need to be aware of include:

The Chromium (VI) compounds proposal update

• Note that the 6-month public consultation period started in June 2025.

The addition of N,N-dimethylacetamide (DMAC) and 1-ethylpyrrolidin-2-one) NEP) to Annex XVII of REACH (with specific exposure limits)

• Note that this amendment entered into force on June 23, 2025 with transitional periods of one and a half, and four years.

The addition of 3 substances to the SVHC list under EU REACH

• These SVHCs were added on June 25, 2025 and companies have six months (December 2025) to notify ECHA if they use any of the newly added SVHC in a quantity greater than 0.1% w/w.

The 23rd adaptation to Technical Progress for the CLP

• Note that this adaptation includes the addition of 22 new substances and amendments to 10 existing substances. Companies should be aware that the application of this amendment to the CLP is mandatory starting February 1, 2027.

The EU Cosmetic Regulation Update

• Note that there are updates to Annex II and Annex III that have a transitional period starting September 01, 2025.

Key Compliance Takeaways for Businesses 

Companies should be aware of the above developments and should keep track of the plethora of deadlines that affect their business workflows. Companies should scan their products for specific chemicals and cross-check those chemicals with lists of regulated chemicals under a variety of EU regulations.   

Companies in the UK should keep track of changes to UK REACH transitional deadlines and the three new options for proposed deadlines. There are also reforms (with consultation closing August 18, 2025) regarding GB Chemical Regulations (BPR, CLP, PIC). The new approach is to standardize and simplify the process of compliance.  

How 3E can help 

Understanding the details of a variety of specific regulations in the EU is a challenge, particularly when applied to member states. With the right approach, companies can achieve compliance. It is important to keep track of which chemicals are used in each product line. The first step is to know exactly which chemicals are used in your products. The next step is to identify applicable regulatory requirements.  

Software is a helpful tool for this. 3E offers a portfolio of products that help industries in many sectors.    

See 3E ERC and 3E ERC+ for more information. 

APAC: Regulatory Developments to Watch

One of the most pressing updates for Asia-Pacific (APAC) comes from Korea.  Korea's National Institute of Chemical Safety (NICS) published a draft classification that introduces three new groups of hazardous chemicals derived from toxic substances (eliminating the category of “toxic chemicals” and replacing that hazardous category with: acute hazards to humans, chronic hazards to humans, and hazards to ecological systems. These changes apply to chemicals covered by the Chemical Control Act (CCA) and K-REACH. Companies should be aware that the changes will take effect on August 7, 2025.

The main updates in this proposal include:

• The publication of a list of toxic chemicals along with their concentration thresholds and other hazard criteria to be reclassified within these three groups
• A comprehensive update on GHS reclassifications for the three groups of hazardous chemicals (previously classified as toxic), and updates for other regulated chemicals (e.g., restricted, banned, etc.)
• There is a one-year transitional period of July 1, 2026

Key Takeaways for Businesses

Companies operating in Korea should review changes to chemical classifications in detail, as they will affect Korean SDS, labeling, and GHS classifications. There are a number of other developments throughout APAC, including an update to the notification website in Thailand – without any announcement – that includes a new  updated website portal related to imported and manufactured chemicals from 2024 under the List 5.6 notification scheme. Companies should be aware that the deadline for notification has already passed, and they should verify compliance as soon as possible.

In Vietnam, companies should be aware of the 2025 Law on Chemicals that was passed on June 14, 2025 which becomes effective on January 1, 2026 (with a transitional period built into it). The new Law on Chemicals will introduce an improved chemicals management scheme affecting the responsibilities of chemical importers and manufacturers. Finally, companies should be aware of GHS developments on the final GHS regulations/standards of countries that have already adopted GHS revisions 7 and 8, such as China and Taiwan, as well as   the potential development of more countries to comesuch as Malaysia and Japan, along with EPR changes throughout the APAC region that should be tracked.

How 3E can help 

APAC developments are fast approaching which will impact countries with varying requirements. Companies may operate in many APAC countries or in just a few. However, nonetheless, it is critical to keep up-to-date on emerging regulations.

Software is a helpful tool for this. 3E has a portfolio of products that help industries in many sectors.

See 3E Generate for more information.

Actionable Insights for Navigating Q2 2025 Regulatory Changes

3E can help address challenges in navigating specific regulations in different countries. There are requirements that impact chemical lists, chemical classifications, and EPR strategies and workflows. 3E Generate and 3E Authoring Services can help companies in any industry or location.  3E software such as 3E Insight also helps to accelerate market readiness.

To stay current with all of the latest regulatory updates, join us at our next Regulatory Roundup webinar (Q3 and Q4) and remember to watch our Q2 webinar for more details on the deadlines mentioned in this blog. Find details in the 3E webinar resource center.

To learn more about 3E's solutions in managing regulatory compliance complexities, contact a 3E expert.